Related-Party Pricing, Even Within India.
Advisory on specified domestic transactions between related parties, including transactions with tax holiday and profit-linked deduction units.
Book Free ConsultationTransfer pricing rules are not limited to cross-border dealings; certain transactions between resident related parties — particularly those involving units claiming a tax holiday or profit-linked deduction — are also required to be priced at arm's length.
At N D Savla & Associates, we identify specified domestic transactions, benchmark them where required, and prepare the documentation and Form 3CEB reporting applicable to such dealings.
We also advise on structuring inter-unit transactions within a single legal entity, where profits are shifted between a tax holiday unit and the rest of the business.
Our Domestic Transfer Pricing Services
Specified Domestic Transaction Identification
Identification of domestic transactions falling within the scope of Section 92BA.
Tax Holiday Unit Pricing Advisory
Advisory on pricing transactions between a tax holiday unit and other units of the same entity.
Related-Party Transaction Review
Review of transactions with domestic related parties as defined under the Act.
Domestic Benchmarking
Benchmarking analysis specific to domestic comparable transactions and companies.
Form 3CEB Reporting for Domestic Transactions
Compilation and reporting of specified domestic transactions in Form 3CEB.
Inter-Unit Profit Allocation Advisory
Advisory on reasonable profit allocation between related units within one entity.
Threshold Monitoring
Monitoring of the aggregate value of domestic transactions against the applicable threshold.
Domestic TP Documentation
Preparation of documentation supporting the arm's length nature of domestic dealings.
Our Advisory Process
Transaction Scan
Domestic transactions with related parties and associated units are scanned for coverage.
Threshold Check
The aggregate transaction value is checked against the specified domestic transaction threshold.
Benchmarking
Applicable domestic transactions are benchmarked against comparable data.
Documentation & Form 3CEB
Supporting documentation is prepared and reported in Form 3CEB.
Annual Review
The position is reviewed each year as transaction values and units change.
Why It Matters
Frequently Asked Questions
Have related-party transactions within India?
Tell us about the entities and units involved — we'll confirm whether domestic TP rules apply.
